FAR 52.204-17—Ownership or Control of Offeror.
Plain-English Summary
FAR 52.204-17, Ownership or Control of Offeror, is a solicitation provision that requires an offeror to disclose basic ownership structure information when submitting an offer. It defines key terms used to identify the offeror’s immediate owner and, if applicable, the highest-level owner, and it explains how to report that information using CAGE codes and legal entity names. The provision also addresses special situations such as joint ventures, where more than one participant may have an immediate owner and each participant may need to provide separate responses. In practice, this provision helps the Government understand who directly controls the offeror and whether that owner is itself controlled by another entity, which supports responsibility determinations, integrity screening, and accurate contractor records. It is especially important that the legal name be reported correctly and that a “doing business as” name not be substituted for the actual legal entity name. The provision is primarily an administrative disclosure requirement, but inaccurate or incomplete ownership information can create proposal compliance issues and downstream registration or award problems.
Key Rules
Key ownership definitions
The provision defines CAGE code, immediate owner, and highest-level owner. These definitions control how the offeror identifies the entities that must be disclosed and how the ownership chain is traced.
Disclose whether an immediate owner exists
The offeror must state whether it has an immediate owner. If it does not, no further ownership disclosure is required under this provision.
Report each joint venture participant
If the offeror has more than one immediate owner, such as in a joint venture, the offeror must answer the ownership questions for each participant separately. This ensures the Government receives ownership information for every controlling participant.
Provide immediate owner details
If the offeror has an immediate owner, it must provide the immediate owner’s CAGE code and legal name, and it must indicate whether that immediate owner is owned or controlled by another entity.
Provide highest-level owner details when needed
If the immediate owner is owned or controlled by another entity, the offeror must identify the highest-level owner by CAGE code and legal name. The highest-level owner is the top entity in the control chain and has no entity above it controlling it.
Use legal names, not trade names
The provision expressly says not to use a 'doing business as' name. The offeror must provide the actual legal entity name associated with the CAGE code and ownership record.
Responsibilities
Offeror
Determine whether it has an immediate owner, identify the immediate owner and any highest-level owner, and complete the provision accurately in the solicitation response. The offeror must provide correct CAGE codes and legal names and must answer separately for each participant if it is a joint venture or otherwise has more than one immediate owner.
Immediate Owner
Although the provision places the reporting duty on the offeror, the immediate owner may need to furnish accurate legal name and CAGE code information and confirm whether it is owned or controlled by another entity so the offeror can complete the representation correctly.
Highest-Level Owner
If identified, the highest-level owner must be accurately named and matched to the correct CAGE code. The entity itself does not complete the provision, but its identity must be traceable through the ownership chain.
Contracting Officer
Include the provision when prescribed by FAR 4.1804(b), review the offeror’s response for completeness and consistency, and resolve apparent discrepancies between the disclosed ownership information and other registration or proposal data.
Agency/Procurement System
Collect and retain the ownership information as part of the solicitation and award record, and use it to support contractor identification, responsibility review, and data integrity checks across procurement systems.
Practical Implications
Offerors should verify ownership data before submitting an offer, because the CAGE code and legal name must match official records and not a trade name or DBA.
Joint ventures and other multi-owner structures need special attention: each participant may require a separate ownership response, which can easily be overlooked.
A common mistake is stopping at the immediate owner when there is another controlling entity above it; if the immediate owner is controlled by another entity, the highest-level owner must also be disclosed.
Because the provision ties to CAGE codes, offerors should ensure their SAM/CAGE information is current and consistent with the ownership hierarchy they report.
Contracting officers should watch for mismatches between the ownership disclosure, SAM registration, proposal representations, and corporate documents, since inconsistencies can delay award or trigger follow-up questions.
Official Regulatory Text
As prescribed in 4.1804 (b) , use the following provision: Ownership or Control of Offeror (Aug 2020) (a) Definitions. As used in this provision– Commercial and Government Entity (CAGE) code means– (1) An identifier assigned to entities located in the United States or its outlying areas by the Defense Logistics Agency (DLA) Commercial and Government Entity (CAGE) Branch to identify a commercial or government entity by unique location; or (2) An identifier assigned by a member of the North Atlantic Treaty Organization (NATO) or by the NATO Support and Procurement Agency (NSPA) to entities located outside the United States and its outlying areas that the DLA Commercial and Government Entity (CAGE) Branch records and maintains in the CAGE master file. This type of code is known as a NATO CAGE (NCAGE) code. Highest-level owner means the entity that owns or controls an immediate owner of the offeror, or that owns or controls one or more entities that control an immediate owner of the offeror. No entity owns or exercises control of the highest level owner. Immediate owner means an entity, other than the offeror, that has direct control of the offeror. Indicators of control include, but are not limited to, one or more of the following: ownership or interlocking management, identity of interests among family members, shared facilities and equipment, and the common use of employees. (b) The Offeror represents that it □ has or □ does not have an immediate owner. If the Offeror has more than one immediate owner (such as a joint venture), then the Offeror shall respond to paragraph (c) and if applicable, paragraph (d) of this provision for each participant in the joint venture. (c) If the Offeror indicates "has" in paragraph (b) of this provision, enter the following information: Immediate owner CAGE code: ____________ Immediate owner legal name: ____________ (Do not use a "doing business as" name) Is the immediate owner owned or controlled by another entity?: □ Yes or □ No. (d) If the Offeror indicates "yes" in paragraph (c) of this provision, indicating that the immediate owner is owned or controlled by another entity, then enter the following information: Highest-level owner CAGE code: ____________ Highest-level owner legal name: ____________ (Do not use a "doing business as" name) (End of provision)